Title
Chinese Chamber of Commerce vs. Pua Te Ching
Case
G.R. No. 5194
Decision Date
Sep 23, 1909
In a case involving a promissory note, the court ruled that the admission of its genuineness and due execution by the defendants constituted a prima facie case for the plaintiff, and that the lower court had the authority to allow interest on the note.
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Case Digest (G.R. No. 5194)

Facts:

  • Chinese Chamber of Commerce filed a complaint against Pua Te Ching et al. on May 14, 1908, involving an action upon a promissory note.
  • The promissory note was made a part of the complaint.
  • Defendants filed a general denial, admitting the genuineness and due execution of the promissory note.
  • Defendants attempted to prove that the promissory note had been paid by the substitution of another promissory note.
  • Plaintiff admitted that defendants proposed to extend the time of payment but refused the proposal.
  • Lower court allowed the plaintiff to recover the balance of the promissory note with interest at 12 percent.

Issue:

  • (Unlock)

Ruling:

  1. The court ruled that the admission of the genuineness and due execution of the promissory note by the defendants constituted a prima facie case for the plaintiff.
  2. The court ruled that ...(Unlock)

Ratio:

  1. Under Section 103 of the Code of Procedure in Civil Actions, when a promissory note is made a part of the pleadings and the defendant fails to deny its execution under oath, the genuineness and due execution of the note are admitted, and a prima facie case is made out for the plaintiff.
  2. In an action upon a contract to recover money, the only damage that may be recovered is the interest at the legal rate, unless another rate is stipulated.
  3. When a mort...continue reading

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